Discussion Paper, Strengthening Financial Resilience in Superannuation, released in November 2021, summarises APRA’s current expectations and calls for submissions from RSE licensees and other industry stakeholders.
As one of the leading consultancy firms in the superannuation industry, Deloitte welcomes the opportunity to respond and provide feedback into an important, complex issue for the industry, which we are comfortable with APRA making available publicly.
We note that APRA has asked specific questions in relation to six subject matter areas. We have not sought to specifically answer each question, but rather to provide our observations on how we consider that APRA might consider providing guidelines or regulatory frameworks to the industry.
In particular, our purpose in making this submission is to draw attention to the emphasis that superannuation funds should have on their approach to risk management and that this should be aligned to funds’ risk appetite statements, which should, in turn, be publicly available and accessible to all members and stakeholders of the funds.